On Jan. 2, 2008, the Environmental Protection Agency (EPA) published the final iron and steel foundry area source rule in the Federal Register.  EPA issued the standard based on generally available control technology (GACT) for the control of the following urban hazardous air pollutants (HAPs):  chromium, lead, manganese and nickel.  The final rule sets emission limits for large area source facilities and requires them to comply with pollution prevention management practices and notification and record keeping requirements. 

Mercury Switch Removal Scrap Management Plan

All iron and steel facilities (both large and small) that are subject to the final area source rule must comply with pollution prevention management practices, notification requirements and record keeping provisions. On Jan. 4, 2010, metalcasting facilities must have a management plan to address the mercury switch removal requirement.

Pursuant to this requirement, foundries may purchase scrap from motor vehicles only from scrap providers participating in an EPA-approved program for mercury removal or operate a site-specific mercury switch removal program at the foundry.  Most foundries will elect to purchase scrap from providers with approved mercury switch programs.  In the final rule, EPA defined “motor vehicle scrap” for purpose of this provision to include only motor vehicle scrap that is shredded.  Other types of scrap from motor vehicles that would not contain mercury such as brake rotor or pump casings would not be subject to this limitation to address mercury switch removal. 

In addition, foundries must submit notification of compliance with the mercury switch scrap management plan requirement by February 3, 2010.  This notification should be sent to the appropriate EPA regional office.

Semi-Annual Compliance Report

The final rule for iron and steel foundry area sources includes a comprehensive set of specific regulatory requirements.  For example, foundries must submit the semi-annual compliance report on Jan. 30, 2010.  Facilities also should review the entire regulatory text to ensure compliance with all of the applicable requirements. 

Additional information on the final iron and steel foundry area source rule is available on the AFS website at www.afsinc.org.  If you have any questions regarding the final rule, contact Christian Richter or Jeff Hannapel at This e-mail address is being protected from spam bots, you need JavaScript enabled to view it or This e-mail address is being protected from spam bots, you need JavaScript enabled to view it .